ILLINOIS POLLUTION CONTROL BOARD
    October
    1,
    1992
    IN THE MATTER OF:
    )
    )
    ADJUSTED STANDARD OF C.J.
    )
    AS 92-6
    GOODALL
    TIRE CO.
    INC. FRON
    )
    (Adjusted Standard)
    3~IlY.TAdflt.
    Cödè
    848.~O2
    (USED
    AND
    WASTE
    TIRES)
    )
    ORDER OF
    THE
    BOARD
    (by G.T. Girard):
    On September 8,
    1992, petitioner filed a petition requesting
    an adjusted standard from the Board’s Used and Waste Tire
    regulations.
    (35 Ill.
    Adin. Code 848.)
    The specific request in
    the petition is for relief from the 14-day storage provisions.
    However, the suggested language includes relief from the removal
    cost estimate requirements as well as aisle spacing and storage
    arrangements.
    The requirements for the
    contents of a petition
    for an adjusted standard are found in the Board’s procedural
    rules at 35 Ill.
    Adin. Code 106.705.
    The petition received by the
    Board is deficient in some respects.
    Areas where more
    information is needed include the following:
    1.
    Tire inventory data.
    Since the focus of the
    requested relief is the storage of over—sized
    tires, the petition should include the number of
    over—sized tires stored in the tire yard as well
    as the number of oversized tires that are repaired
    and sold on a monthly or annual basis.
    2.
    Compliance alternatives and cost issues.
    The
    petitioner should provide additional information
    regarding:
    a)
    A Detailed explanation of why the use of a tarp
    failed to be adequate and whether there are different
    types of tarps or similar materials that are available
    in the market place for covering used tires to prevent
    water seepage, as well as the cost of such materials.
    b)
    An explanation of why storage of over-
    sized tires in an open-sided building is not
    a viable alternative.
    C)
    A discussion of the costs associated with
    each alternative as well as other material
    factors such as labor costs and practical
    problems.
    3.
    An explanation of how petitioner will comply with
    all other management standards of Part 848
    0136-0269
    2
    including tire storage arrangement and aisle space
    (Pet.
    at 10).
    The Board notes that based on the
    dimensions of the existing tire storage units
    (90
    feet by 100 feet)
    (Pet. at 4 and Ex.
    5),
    it
    appears that the 25-feet aisle space maintained
    between the units is less than the minimum
    separation distancer req~ifred ~
    regulations at 35 111. Ada. Code 848.202
    (c) (5) (B).
    4.
    Justification for the inclusion in the proposed
    adjusted standard of an exemption that allows
    petitioner to exclude one fourth of the previous
    year’s tire production when estimating the cost of
    tire removal under
    35 Ill Ada. Code 848.404
    (Pet.
    at 6).
    5.
    Justification for the alternate management
    standards proposed by the petitioner which
    requires the implementation of a plan that
    includes alternate tire storage arrangements and
    aisle space
    (Pet.
    at 6).
    The Board also notes that the language for the proposed
    adjusted standard is in regulation form; more specific language
    should be drafted in the format of an adjusted standard.
    In
    addition, the Board has not received the certficate of
    publication required by 35 Ill. Ada. Code 106.
    The Board directs
    the petitioner to file an amended petition addressing at least
    the factors outlined above no later than November 15,
    1992 or the
    petition may be subject to dismissal.
    IT IS SO ORDERED
    I, Dorothy N. Gunn,
    Clerk of the Illinois Pollution Control
    BoaTd, hereby cert
    y that the above order was adopted on the
    /‘~
    day of
    /
    ~—~-t)
    ,
    1992, by a vote of
    7-c.
    Dorothy M4~unn, Clerk
    Illinois ~llution
    Control Board
    0136-0270

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